On Monday, Sept. 10, 2012, the United States Department of Justice filed a Second Amended Civil Complaint involving the online poker indictments from April 15, 2011, introducing new forfeiture charges against Howard Lederer and Ray Bitar including houses and automobiles purchased with “illegal proceeds.”

The Second Amended Complaint also added the Travel Act 18 U.S.C. § 1952 as a Federal criminal statute in support of their forfeiture request. The Travel Act essentially forbids the use of “interstate and foreign travel of transportation in aid of racketeering enterprises.” The inclusion of the Travel Act gives the DOJ another statute to rely on in addition to the IGBA and Wire Act.

The Second Amended Complaint also gives a detailed account of Lederer’s expenditures from the end of 2006 up until September 2011. All told, the complaint shows that $44,314,997.31 associated with criminal conduct was deposited into his various bank accounts. That included $3,654,654.35 paid through personal accounts to Merlin Contracting & Development, LLC for the construction of a main home and guest house in or around 2007. In addition, the complaint alleges $6,859,070 was paid “from the Lederer Personal Account, the Lederer Consulting Account and through cashier’s checks in connection with the construction of the main house.”

The complaint also lists purchases for Bitar including two homes in Glendora, California. Specific expenditures were not listed for defendants Chris Ferguson and Rafe Furst.

Because the listed expenditures can be traced to an “illegal enterprise,” the DOJ seeks forfeitures in the following amounts:

Howard Lederer—$42.5 million

Chris Ferguson—$42 million

Ray Bitar—$40.8 million

Rafe Furst—$11.7 million

The complaint also included eight more “Claims for Relief,” bringing the total to 12 . The claims, if true, would justify the DOJ's request for the aforementioned forfeitures. Here are the 12 Claims for Relief:

Illegal Gambling

Travel Act Offenses

Bank and Wire Fraud

Wire Fraud

Promotion Money Laundering and Conspiracy

Concealment Money Laundering and Conspiracy

International Money Laundering and Conspiracy

Bulk Money Laundering and Conspiracy

Promotion Money Laundering and Conspiracy Relating to Full Tilt Fraud Against Players

Concealment Money Laundering and Conspiracy Relating to Full Tilt Fraud Against Players

International Money Laundering and Conspiracy Relating to Full Tilt Fraud Against Players

Bulk Money Laundering and Conspiracy Relating to Full Tilt Fraud Against Players.

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